ML20236P008
| ML20236P008 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 05/20/1987 |
| From: | TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | |
| Shared Package | |
| ML20236N530 | List:
|
| References | |
| DAP-2, NUDOCS 8708120187 | |
| Download: ML20236P008 (66) | |
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TITLE I-DOCUMENTATION AND TRACKING OF ISSUES AND DISCREPANCIES NUMBER DA P-2 Revision Prepared Date Reviewed nate Aporov,ed Date h
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TABLE OF CONTENTS' Section Pace Cover Sheet..........................................
'i Table of Contents....................................
11
~1.0' PURP0SE.........................................
1 2.0' SCOPE...........................................
1 U
3.0 DEFINITIONS AND. RESPONSIBILITIES................
1 4.0 INSTRUCTION.....................................
18 b 5.0 DOCUMENTATION...................................
35
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ATTACHMENTS A
ISSUE RECORD COVER SHEET........................
A-1 B
CONSTRUCTION QA/QC ISSUES L0G...................
B-1 C
ISSUE REC 0RD....................................
C-1 D
DISCREPANCY / ISSUE RESOLUTION RECORD.............
D-1 E
INTERPRETATION OF DAP TRACKING SYSTEM
" TYPE" BL0CKS...................................
E-1 through E-3 F.
USE AND INTERPRETATION OF DESIGN ACTIVITY.................................
F-1 through F-4 b.
TN-86-6262/2 ii I
'n COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 OL)
' ISSUES AND DISCREPANCIES 1.0 PURPOSE This procedure defines the requirements for documentation, tracking and resolution of External Source Issues and of discrepancies identified during the conduct of the Design Adequacy Program (DAP) and the Civil /
Structural / Mechanical (CSM) ISAPs that are part of the CPRT Program Plan.
2.0 SCOPE This procedure applies to issues identified by external sources and to discrepancies identified during implementation of the self-initiated portion of the DAP. Where indicated, this procedure also applies to documentation of DAP overviews of corrective action; capture of informa-tion about TUGC0-identified reportable or potentially reportable issues; and documentation of discrepancies found during evaluations conducted under the CSM ISAPs.
3.0 DEFINITIONS AND RESPONSIBILITIES 3.1 Definitions 3.1.1 External Source Issue An error or concern related to design or design processer identified by an organization other than the Comanche Peak Project or the Comanche Peak Response Team (CPRT) and contained in public documents on the NRC dockets for the Comanche Peak Steam Electric Station (CPSES).
Open External Source Issues are documented in "E"
type Discrepancy / Issue Resolution (DIR) Reports. External Source Issues resolved by an external source are documented in "R" type DIRs.
TN-35-6262/2 pace 1 of 53 1
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES
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3.1.2 Status The designation, as determined-under the DAP, of an issue or discrepancy as open or closed, and whether it has been. transferred to a primary issue or is a duplicate of another issue already entered in the DAP j
tracking system.
3.1.3 Open 3.1.3.1 Open External Source Is' sues i
Issues are considered to be open until there is reasonable assurance 3
that the following conditions, as determined under the DAP, have been met:
o It has been determined that:
O a) the issue is unsubstantiated, or, b) the issue I
i) has been resolved by an external source and requires no additional investigation by the CPRT except as an input to trend evaluation, and ii) has bee'n appropriately classified by the CPRT (e.g.,
as an observation, deviation or deficiency); or, c) the issue is a discrepancy determined by the CPRT to have l
been resolved and meets the conditions for closure of a discrepancy. listed in paragraph 3.1.3.2 of this proced-ure; and, The bases for any one of.the above. mentioned determinations o
have been documented.
This definition applies only to "E" type DIRs.
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6
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ISSUES AND DISCREPANCIES 3.1.3.2 Open DAP-Identified Discrepancies Discrepancies are considered to' be open until there is reasonable assurance that the following conditions, as determined under the DAP, have been met:
1 i
The DAP has determined that the discrepancy has been appropri-l o
ately classified (e.g.,
as an observation, deviation or de ficiency).
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The DAP has determined that appropriate resolutions and 1
corrective actions, as required by the CPRT Program Plan and I
DAP-20, have been established.
o It has been determined that the root cause and the generic i
implications for certain classifications of DIRs have been investigated as required by the CPRT Program Plan.
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o The basis for the above-mentioned determinations have been documented.
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This definition applies only to "D" type DIRs.
3.1.4 Closed Issues and discrepancies are considered closed when the applicable conditions outlined in 3.1.3 have been met.
This definition applies to "E",
"R" and "D" type DIRs.
3.1.5 Transferred to The designation used to describe the result of (1) combining duplicate issues that appear in o.ne or more of External Source documents, (2) combining duplicate discrepancies that have been entered in the DAP tracking system, or (3) combining DAP-identified, related discrepancies
("D" DIRs) or External Source Issues into primary issues.
The issue to G
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING 0F Revision: 6 Q
ISSUES AND DISCREPANCIES which duplicate issues, or related discrepancies (that may be addressed in an IRR) are transferred is referred to as the primary issue.
3.1.6 Classification The designation used to indicate the characteristics of an issue or discrepancy regarding its validity, consistency with design commitments and nuclear safety-significance.
The classifications are:
unsubstanti-
- ated, observation, deviation, unclassified deviation, unclassified trend, deficiency and programmatic deficiency.
Figure 1 depicts the relationship among the classifications.
(Note: The arrows indicate the general progression of classifications, but do not limit the proper reclassification of issues or discrepancies that were improperly classified.)
3.1.7 Unsubstantiated An External Source Issue or DAP-identified discrepancy that has been determined, by the DAP, to be not valid.
3.1.8 Discrepancy Any identified error related to design inputs, implementing documents and outputs, i.e.,
assumptions, procedures, calculations, analyses, drawings or specifications for safety-related structures, systems or components that could have an adverse impact on the adequacy of their design.
All discrepancies are ultimately either classified as observa-tions, deviations, unclassified deviations, deficiencies or programmatic deficiencies, or are found, upon additional investigation by the DAP, to be unsubstantiated.
Substantiated issues become discrepancies within the DAP.
TN-85-6262/2 Pace 4 of 53
O ACTION PLAN RESULTS d
EXTERNAL NOT EXPLICITLY DEFINED E
ADVERSE SOURCE BY AN EXTERNAL TREND ISSUE SOURCE ISSUE m
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UNSUBSTANTIATED 9
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DISCREPANCY n
'V OBSERVATION DEVIATION u
v PROGRAMMATIC UNCLASSIFIED DEFICIENCY DEFICIENCY DEVIATION FIGURE I RELATIONSHIP AMONG CLASSIFICATIONS n
v TN-85-6262/2 Page 5 of 53 i
l 9-l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES 3.1.9 Observation Any identified, substantiated design discrepancy that has been determin-ed, under the DAF, not to constitute a design deviation. An observation may be technical (related to a technical aspect of design) or program-matic.
3.1.10 Deviation Any identified design that has been determined, under the DAP, to constitute a verified failure to meet a design criteria commitment or specification.
In this regard, design criteria commitments include regulatory requirements, FSAR commitments, other licensing commitn.!nts, applicable code and standard requirements or other project-specific design criteria or commitments.
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3.1.11 unciassif4ed Dev4at4en A deviation or set of devi&tions for which it has been determined that it is, more practical to proceed. directly to analyzing root cause and generic implications and specifying corrective actions.
A safety-sig-nificance evaluation will not be done for unclassified deviations because it would serve no useful purpose. ' Unclassified deviations will be tracked as deficiencies in that root cause, generic implications evaluations, and corrective action will be evaluated.
In areas where reverification or redesign is being performed, the assessment of root cause and generic implications is only for the purpose of identifying potential problems in other design areas.
Discrepancies noted during DAP overview of corrective action are discussed in Section 4.8.
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o COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES 3.1.12 Deficiency Any identified design deviation that has been determined, under the DAP, to be a safety-significant deviation.
3.1.13 Programmatic Deficiency A set of related design discrepancies that have been determined to constitute an adverse trend that is programmatic in nature.
An adverse trend is referred to as a programmatic deficiency. A trend is consider-ed to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetect-ed safety-significant deficiency in the affected design area.
A programmatic deficiency can include any identified design control program deviation meeting one or more of the following criteria:
O o
inadequacy of a design control program element such that substantive revision of the program or other corrective action is required to bring it into compliance with the regulatory requirements, FSAR commitments, or other licensing commit-ments; or o
Extensive evaluation would be required to determine the effect on the quality of design.
Programmatic deficiencies (like design deficiencies) are subject to evaluations of safety-significance (DAP-22), root cause and generic implications (DAP-7), and adequacy of corrective action (DAP-20).
A programmatic deficiency may be identified during the preparation of Issue Resolution Reports.
Trends (whether adverse or unclassified) may be documented on DIR forms in accordance with this procedure, in engineering evaluations prepared in accordance with DAP-8, or in results reports prepared in accordance with DAP-9.
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES 3.1.14 Unclassified Trend A trend for which it has been determined that it is more practical to proceed directly to analyzing root cause and generic implications and specifying corrective actions.
A safety-significance evaluation will not be done for unclassified trends because it would serve no useful purpose.
Unclassified trends will be tracked as adverse trends (pro-grammatic deficiencies) in that root cause, generic implications, and corrective action will be evaluated.
In areas where reverification or redesign is being performed, the assessment of root cause and generic implications is only for the purpose of identifying potential problems in other design areas.
Discrepancies noted during DAP overview of corrective action are discussed in Section 4.8.
3.1.15 Safety Significant O
A deviation that, if uncorrected, would result in the loss of capability of the affected system, structure or component to perform its intended safety function. Credit is not allowed for redundancy at the component, system, train or structure level.
Refer to Appendix E, CPRT Program Plan for additional information regarding the CPRT definition of safety I
1 significant.
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3.1.16 Root Cause l
The cause or causal factors that contributed to a programmatic deficien-cy, unclassified deviation, unclassified trend, or design deficiency, (i.e., why it occurred).
A root cause may be determined during an evaluation by testing a hypothesis or by making a preliminary judgement subject to confirmation.
Root causes and causal factors and the extent of' their applicability in design are based on objective evidence. They are confirmed and bounded by the findings of evaluations (what does TN-85-6262/2 Page 8 of 53
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s COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 l
ISSUES AND DISCREPANCIES exist) rather than by general statements of what could exist.
In special cases, actions beyond those listed for any given classification may be warranted.
For example, it may be considered appropriate to assess root cause for a particular deviation or non-adverse trend.
3.1.17 Generic Implication A reasonable likelihood that an issue or discrepancy (DIR) affects some aspect of design other than-the specific instance in which the finding was identified.
3.1.18 Generic Implications Evaluation The process of reviewing programmatic deficiencies, unclassified deviations, unclassified trends, or design deficiencies identified in self-initiated portions of the DAP, or originated as External Source O
Issues and confirmed by the DAP to:
Determine whether related design deficiencies exist, o
Investigate the root cause or causal factors, o
Determine limiting boundaries of applicability of the defic-o iency under review.
In special cases, actions beyond those listed for any given classifica-tion may be warranted.
For example, it may be considered appropriate to assess generic implications for a particular deviation or non-adverse trend.
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES 3.1.19 Issue Record A form (DAP-2-3) prepared by the Design Adequacy Review Team during the review of External Source documents which contains a description of the issue and a record of its disposition by the DAP (See Attachment C).
3.1.20 Issue Record Cover Sheet A form (DAP-2-1) prepared by the Design Adequacy Review Team that identifies the source document for an attached set of Issue Records (See Attachment A).
3.1.21 Construction /QA/QC (QOC) Issues Log A form (DAP-2-2) prepared by the Design Adequacy Review Team during the review of External Source documents that lists issues that are within O
the scope of the QOC Program ('See Attachment B).
Use of this form is optional.
3.1.22 Discrepancy / Issue Resolution Report (DIR)
A form (DAP-2-4) prepared by the Design Adequacy Review Team for entry in the Tracking System to track the status, classification and resolu-tion of a'll open issues and of all discrepancies identified during conduct of the DAP (See Attachment D).
3.1.23 Issue Resolution Report (IRR)
.A type of engineering evaluation prepared in accordance with DAP-8 that provides an integrated summary of the concerns expressed in DIRs and that sets forth the criteria by which DAP will evaluate any proposed corrective action.
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6 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 b-ISSUES AND DISCREPANCIES 3.1.24 Primary Issue An optional type of DIR that is originated (or revised) to reflect all ld aspects of (I) duplicate External Source Issues
("E" type DIRs),
(2) duplicate DAP-identified discrepancies that are found to have been entered in the DAP Tracking System ("D" type DIRs), or (3)
"E" or "D" type DIRs that are not duplicates but are related to a technical or programmatic design 1:: sue and are grouped into a single DIR. Relateo DIRs may be grouped as an input to an IRR, as documentation of a trend or as a compilation of DIRs that facilitates evaluation, resolution, or closure regardless of whether the primary DIR is included in an IRR or a trend.
A primary issue DIR that is the subject of an IRR may be classified as an unclassified deviation, a programmatic deficiency, or other classification as appropriate.
3.1.25 "C" Type DIR mU A computer record subject to in-process revision in the general format of Form DAP 2-4 that documents a discrepancy found as a result of DAP overviews of corrective action or as a result of DAP review of Project DIR Resolution Forms.
"C" DIRs are not required where DAP findings k
serve as direct input to the TU QA program.
These DIRs are not part of either the External Source Issue review or the self-initiated part of the DAP.
Section 5.5.8 defines the information required in "C" DIRs.
"C" DIRs are open until adequate information is received to allow resolution of the DIR.
3.1.26 "T" Type DIR A computer record subject to in-process revision in the general format of Form DAP 2-4 that documents selected evaluations done outside the DAP in response to a problem related to design. Sections 5.5.7 defines the
,,d TN-85-6262/2 page 11 of 53
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COMANCHE PEAK RESPONSE TEAM - D. N 3N ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES information required in "T" DIRs.
"T" DIRs are for "information only" g
and no closure by the DAP is required, a
3.1.27 "D" Type DIR A computer record subject to in-process revision in the format of Form DAP 2-4 that documents a discrepancy (or other classification including programmatic deficiency) identified either by the self-initiated portions of the DAP or by third-party investigations of External Source Issues.
3.1.28 "E" Type DIR A computer record in the format of Form DAP 2-4 that documents open Issue Records (Form 2-3) in a format that allows resolution.
(Note:
Issue Records record the historic statement of the issue as expressed by
_O the exteraa, source.
Issue Records are not subaect to revision other than correction of mistakes, such as computer entry errors, etc.)
3.2 Responsibilities 3.2.1 Review Team Leader The Review Team Leader is responsible for:
Approving the' classification of discrepancies as deficiencies, o
programmatic deficiencies, unclassified trends, or unclassi-fied deviations; Approving the closure of deficiencies, programmatic deficien-o cies, unclassified trends, and unclassified deviations; O
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$0MANCHE PEAK RESP 0flSE TFAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2 i
TfA}e: DOCU'tENTATON AND TRACKING 0F Rivision: i 4}.
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ISSUES AND DISCREPANCIES a
y o ', Trar,smittino de#icie1cies / programmatic deficiencies, unclas-
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,sifief trends, \\end unclassified dev.ations,to the CP87-
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ke,iorleview Team,an,d to appropriate Project personnel.
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These responsib41 ties may be deleoated to the DAP Manager; s
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The Review Tead Leader may perform any of the functions of the Revin-ers, Discipline Coordinators, td9 Generic Implication; Coordinates or the DAP Manager, 1
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3.2.2 Desi 7. Adequacy Program Manager (DAP Manager) 9 The DAP Manager is, respcanible for:
Approvin? 'the classification of discrepancies as deviations; o
Coricurring in (or approving, if authorized by the Review Team o
/~l leader) the classification of discrepancies as deficiencies, Y;s programmatic deficiencies, unclassified trends, or unclas-r:fied deviations; i,
o Approving the closure of.devittions; Recommending (or approving, if authorized by the Review Team o
Leader) closure of; deficiencies, programmatic deficiencies, uncltstified trends, and unclassified deviations; o
Transmitting to appeepriate Project personnel on a weekly basis copies of new an'..I revised DIRs that are:
"D" DIRs "E" DIRs classified as a deviation, unclassified devia-tion, unclassified trend, deficiency, or programmatic deficiency "C" DIRs i
IC However, changrid DIRs that do not have a new revision number
/A t:o not need to be sent to the Project.
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_7N-85-676?/7 Pace 13 of 53
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COMANCHE PEAK RESPONSE TEAM - DF. SIGN ADEQUACY PROCEDURE Number:
DAP-2
Title:
DOCUMENTATION AND TRACKING 0F Revision: 6
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ISSUES AND DISCREPANCIES The DAP Manager may perform any of the functions of the Reviewers, Discipline Coordinators or the Programmatic / Generic Implications Coordinator.
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3.2.3 Programmatic / Generic Implications (PGI) Coordinator The Programmatic / Generic Implications Coordinator (or his designee) is responsible for:
o Assigning numbers to approved Issue Records and DIRs; Ensuring data entry to the Design Adequacy Program Tracking o
System; Revising DIRs to correct or enter missing data as delegated in o
this procedure or by the DAP manager; o
Managing the DAP Tracking System (DAPTS);
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Issuing periodic status reports to addressees as determined by o
the DAP Manager; Ensuring that a DIR is created for each open Issue Record; o
Returning unsigned hard copies of DIRs to Discipline Coordi-o nators for review and potential revisions; o
Maintaining an auditable record of all Issue Records, DIRs, and revisions to DIRs in the form that they were entered in the Tracking System.
o Performing the Discipline Coordinator's functions related to DIRs generated within the PGI discipline.
3.2.4 Discipline Coordinator The Discipline Coordinator is responsible for:
o Approving Issue Record Cover Sheets, QOC Issues Logs, and Issue Records; O
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I
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 Q
ISSUES AND DISCREPANCIES Concurring with the identification of External Source docu-o ments which discuss QOC issues; Approving the status of External Source Issues; o
Approving the classification of closed External Source Issues; o
o Identifying duplicate' External Source Issues or related DAP-identified discrepancies and approving the transfer of duplicate issues or DAP-identified discrepancies to the primary issue; o
Approving the classification of open issues as unsubstantiated issues or as discrepancies; o
Performing actions for which a reviewer is responsible (Section 3.2.5);
Concurring with or approving DIRs (depending upon classifica-o tion as detailed in Section 4);
o Approving the identification of discrepancies that are not explicitly defined by an External Source Issue; O
Approving the classification of discrepancies as observations; o
o Approving the closure of observations; Concurring in the classification of discrepancies as devia-o tions, deficiencies, programmatic deficiencies, unclassified trends, or unclassified deviations; o
Recommending the closure of deviations;
)
o Forwarding copies of Issue Record Cover Sheets for documents j
that discuss 000 issues, and specifically identified issues i
requiring clarification as to DAP versus QOC coverage, to the DAP Construction Quality Interface Manager for transmittal to j
the QOC Interface Coordinator (QOC Issued Logs or Issue Records may be included at the discretion of the Discipline Coordinator);
o Forwarding signed Issue Record Cover Sheets and Issue Records to the Generic Implications Coordinator;
)
o Forwarding DIRs for which the recommended classification is l
deviation, deficiency, unclassified deviation, unclassified O
1N-es-eze2,2 Peoe Is er s3
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACV PROCEDURE Number: DAP-2
Title:
DOCUMENTATION fND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES trend, or pro 9e mmatic deficiency (including closure of these classifications) to the DAP Manager; Forwarding DIRs and revisions to DIRs to the Generic Implica-o tions Coordinator after appropriate approvals have been obtained; l
Determining whether scope expansion is required, as directed o
in DAP-3; Approving the reassignment of issues or discrepancies to the o
00C Program, TRT Testing Review Team or TRT Electrical Review Team Programs, and transmitting (directly or via the QOC Interface Manager) these issues or discrepancies to the appropriate Review Team Leader; Ensuring that, within his discipline, all open issues, and all o
discrepancies not explicitly defined by External Source Issues, are closed prior to the completion of the DAP; Ensuring that machine-printed outputs (hard copies) of DIRs o
from the DAP Tracking System are reviewed.
3.2.5 Reviewer The Technical Reviewer is responsible for:
o Reviewing External Source documents; o
Identifying External Source Issues; o
Preparing Issue Record Cover Sheets; o
Preparing QOC transmittals including Issue Record Cover Sheets, Issue Records, or 00C Issue Logs as appropriate; o
Preparing Issue Records; Recommending the status of External Source Issues; o
o Recommending the classification of closed External Source Issues; TN-85-6262/2 Page 16 of 53
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COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 p
ISSUES AND DISCREPANCIES V
Recommending the classification of open issues as unsubstan-o tiated issues or as discrepancies; Identifying discrepancies that are not explicitly defincd by o
External Source Issues; o
Preparing DIRs and revisions to DIRs; Recommending the classification of discrepancies; o
Reviewing information provided by others to close issues or o
discrepancies; o
Forwarding Issue Record Cover Sheets, Issue Records, Q00 Issues Logs, DIRs, and revisions to DIRs to the Discipline Coordinator; Reviewing machine-printed outputs (hard copies) of the DIRs o
from the DAP Tracking System for accuracy, and revising them as necessary.
3.2.6 Construction Quality Interface Manager O
The Construction Quality Interface Manager is responsible for forwarding 1
information received from the Discipline Coordinators on 00C issues to the appropriate QOC program interface person, and for maintaining a record or copy of information transmitted to the QOC Program.
(Inter-faces with the TRT Testing Review Team or the TRT Electrical Review Team are the responsibility of the DAP Discipline Coordinator who identifies an issue t,at should be transferred to either of these teams.)
i 3.2.7 TRT Issues Manager The TRT Issues Manager's responsibilities for signing DIR forms are the same as the DAP Manager's responsibilities, to the extent that DIRs are generated in the course of TRT reviews.
In these cases, this procedure applies to the TRT Issues Manager wherever the term "DAP Manager" appears.
O 1N-es-sas2/2 eeoe 17 of s3
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s COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6
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ISSUES AND DISCREPANCIES 4,0 INSTRUCTION Effective Date:
For the purpose of entering references in the tracking system data base for Action Plan numbers, Review Topics, HDA numbers, or i
CPSES Project-assigned TDDR numbers, Revision 4 of DAP-2 is considered to have been effective since August 4, 1986.
4.1 Identification of External Issues 4.1.1 General The identification of issues is accomplished by the systematic. review of documents which describe concerns related to the design or design process (External. Source documents).
Identification of External Source Issues is an on-going activity throughout the DAP.
O The Reviewer shall comPiete an Issue Record (usins attached rorm DAP-2-3) for each issue related to the design or design process, regardless of the indicated status of the issue.
1his shall incicde issues identified by the QOC (including QA/QC) Review Team or other TRT Review Team and transferred to the Design Adequacy Review Team for evaluation.
If, during the initial source document review, it is apparent that an issue has both technica, and programmatic components, these components may be documented on a single Issue Record.
The objective of the external source issue review is to ensure that issues raised by external sources are identified and tabulated syste-matica11y so that there is reasonable assurance that all external source b
issues are identified.. Notwithstanding anything to the contrary in this procedure, it is not necessary that duplicate references to essentially O
TN-es-8262/2 Peoe is of sa
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 Iv)
ISSUES AND DISCREPANCIES similar external source issues be recorded on Issue Records or "E" type DIRs.
A reviewer need not record additional references to a previously identified external source issue provided he knows that the issue has g
already been identified, that the new reference to it does not expand the scope of the issue, and that documentation exists to indicate that the external source document has been reviewed.
l 4.1.2 000 or Other TRT Review Team Issues Where an issue is noted by the DAP reviewer to be potentially relevant to the Quality of Construction (QOC) program or other TRT review team, it shall be documented in one of the following forms:
By noting on the Issue Record Cover Sheet (Form DAP-2-1) that o
construction or other TRT review team issues are discussed within the document.
O' o
By noting on the QOC Issues Log (Form DAP 2-2) or Issue Record (Form DAP-2-3) specific issues that require confirmation that they are or are not covered within the scope of the QOC or l
another CRPT Program.
This will typically be done for issues that are not included in the scope of 'the DAP where it is uncertain that they are covered in the scope of the QOC or another CPRT Program, o
By any combination of the above.
4.1.3 Determination of Issue Status For each design issue, the Reviewer will make a determination as to whether the issue is open or closed using the criteria specified in paragraph 3.1.3.1.
Any issue considered unresolved by the External Source will be designated open under the DAP.
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v TN-85-6262/2 Paae 19 of 53 1
_ _ _ ~
1 COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES If the issue is determined to be opi.n, Part 1 of the Issue Record will be completed to the extent appropriate based on External Source document contents in'accordance with paragraph 5.4.1.
If the issue is determ'ined to be. closed, the issue will be classified l
and Parts 1 and 2 of the Issue Record will be filled out as completely as possib1::.
j 4.1.4 Disposition of Issue Records i
When the review of a source document is complete, the Reviewer s. hall attach'an Issue Record Cover Sheet (using attached Form DAP-2-1) to the complete set of Issue Records.
The package will then be submitted by the, Reviewer to the Discipline Coordinator responsible for the review.
The Coordinator responsible for source document review will forward
-portions of the package to the ' appropriate DAP Discipline Coordinator O
ur. rev4ew and appreai e External Source issues 4 thin that disci-pline.
Upon approval of these External Source Issues, the Discipline Coordinator will forward his portion of the package (including Issue Records with original signatures that apply to his discipline) to the Generic Implications Coordinator for entry into the DAPTS.
Issue Records and Issue Record Cover Sheets shall be retained in auditable files by the Generic Implications Coordinator.
As use of QOC Issues Logs is optional, there is no requirement that files of QOC Issues Logs be auditable.
If any QOC issues are identified, the Discipline Coordinator responsible for initial source document review will send a copy of the relevant documentation described in Section 4.1.2 to the QOC Interface Coordin-ator via the DAP Construction Quality Interface Manager.
If issues identified are determined within th'e DAP to be within the purview of a TRT review team, the Discipline Coordinator will send a copy of relevant
_O T
i N-8s-6282/2 ee9e 20 of sa
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING 0F Revision: 6 ISSUES AND DISCREPANCIES documentation to the appropriate TRT Review Team Leader.
All issues that are entered in the DAPTS and then transferred to another review team shall be closed in the DAP tracking system with reference to the transfer memorandum added to the DIR.
For each open issue, the Generic Implications Coordinator (or his designee) will transfer the information from the Issue Record to an unsigned DIR and forward two copies of the DIR to the Discipline Coordinator responsible for the Action Plan designated in the DIR.
The Discipline Coordinator shall distribute one of these copies to the Reviewer to whom he assigns responsibility for review of the Issue Record.
The Discipline Coordinators will review the initial set of DIRs for duplicate issues and will, by revision of the DIRs, designate (in the status field) duplicate issues as " transferred to" and indicate the
'O issue numeer per Section s.s.2 to which the duplicate was transferred (the primary issue).
There are different methods by which a primary issye may be created.
The easiest method to describe a primary issue should be used without creating additional, unnecessary paperwork.
Regardless of the method used, all fields that are filled in on the primary issue should be checked for accuracy and revised as necessary.
o An existing E-XXXX
("E" type) DIR that encompasses the duplicate issue records may be designated as the primary issue without revising the content of the primary DIR; o
An existing E-XXXX DIR that does not completely encompass all aspects of duplicate issues may be revised to reflect all aspects of duplicate issues and to state in the " Description" block that this DIR is the primary issue and reflects dupli-cate issues, or; l
o A new E-XXXX DIR may be written as the primary issue with the issue description stating that this DIR is a compilation of i
duplicate issues and encompasses all aspects of duplicate O
TN-es-eze m gege 21 e s3
- COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2 Titlei DOCUMENTATION AND TRACKING OF Revision: 6 i
f-ISSUES AND DISCREPANCIES issues.
If a new DIR is created, a new E-XXXX number for the primary issue shall be assigned by the Generic Implications Coordinator (or his designee) for entry in the " transferred to" block of duplicate issues.
During the first revisions to the DIR, each open issue shall be classi-fied as a discrepancy unless the DIR was revised to reflect another classification because additional or revised information developed during the review process.
If it is determined that the DIR is not a DAP-related issue, no classification is needed.
The revised DIR cannot be accepted if the issue is not classified, unless the DIR is transfer-red to a primary' DIR or to a CPRT team outside the DAP.
To be classi-fied as' an observation, the issue must be designated as closed, and a 1
description of resolution (why the DIR is closed) must be included on the DIR.
The Discipline Coordinators will send the revised (signed) DIRs (both O
duplicate and primary issues) to the Generic Implications Coordinator for entry into the DAPTS and retention in the file of Tracking System input forms.
4.2 Identification of Discrepancies by DAP Self-Initiated Proaram Reviewers shall prepare a new DIR for each discrepancy that is found during implementation of a self-initiated part of Discipline Specific Action Plan (DSAP).
Revision 2 of form DAP-2-4 shall be used for DIRs originated by reviewers after March 31, 1986.
DIRs originated before April 1, 1986 may be done using Rev. O of DAP-2-4 and need not be 4
rewritten on a Rev. 2 form. There is no Rev.1 of DAP-2-4.
Do not use i
Rev. O of DAP-2-4 after March 31, 1986.
Future' revisions of DAP-2 forms shall be used for DIRs originated after the effective date of the revision to DAP-2.
l O
TN-85-6262/2 Page 22 of 53 I
~
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision:'6 m
ISSUES AND DISCREPANCIES (J
I 4
.If originated within the DAP, the DTR (D-XXXX DIR), including any supplementary sketches, notes and explanatory information, shall be prepared with the objective of allowing a person not familiar with the l
work, but technically qualified, to understand,it without extensive-additional inquiry and research. Supplementary sketches, notes and explanatory information shall be a part of discipline files.
The DIR shall describe the content of this additional information relative to the discrepancy so that by itself the DIR describes the discrepancy. If the DIR is an External Source Issue, the details of the description are based on information contained in the External Source document.
These details may not be sufficient to enable a technically qualified person to understand the issue without further inquiry or research.
The Discipline Coordinator shall review, approve, and sign the DIR that 4
describes the discrepancy and forward the DIR to the Generic Implica-O tions Coordinator for entry to the DAPTS and retention in the file of Tracking System input forms.
If, during the implementation of an Action Plan, it is determined that the issue / discrepancy under review should be reassigned to the QOC Program for resolution, the issue / discrepancy will be designated as closed, and a copy of the DIR will be forwarded to the QOC Interface Coordinator by the DAP Construction Quality Interface Manager after approval by the Discipline Coordinator.
If an issue / discrepancy should be reassigned to another TRT review team (Testing or Electrical), the DIR will be closed in the DAPTS and sent to the appropriate Review Team Leader by the Discipline Coordinator.
Issues / discrepancies that are transferred to another Review Team need not be classified within the DAP.
O 1w ns.<>r,,,,
..m.
2, m< s, i
I l
1 1
....... I
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number:
DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6
]
ISSUES AND DISCREPANCIES 4.3 Classification of Discrepancies When sufficient information has become available, the reviewer shall classify each discrepancy as either an observation or a deviation.
The classification will be documented by the reviewer through revisiori of the DIR.
If classified as an observation, the DIR must also be marked closed and the' description of resolution included, as no further action other than trending will be taken by the DAP regarding the observation.
Recommended actions by the CPSES Project will not be included in the description of resolution field in the DIR.
Issues classified as unsubstantiated or as discrepancies, and discrepan-cies classified as observations, require the signature of the reviewer and the approval signature of the Discipline Coordinator on the DIR.
g Classification of a discrepancy as a deviation requires the signature of the reviewer, the concurrence signature of the Discipline Coordina-tor, and the approval signature of the DAP Manager on the DIR.
If the discrepancy is determined to be a deviation other than an unclassified deviation, it will be evaluated for safety significance, as required by DAP-22.
Several deviations may be combined into a primary DIR and covered by a safety significance evaluation 6f that primary DIR.
If the deviation is determined to be a deficiency or an unclassified deviation, the DIR will be revised to reflect this new classification.
All deficiencies, programmatic deficiencies, unclassified deviations, and unclassified trends will be evaluated for root cause and generic implications, as required by DAP-7.
The revision requires the signa of the. reviewer, the concurrence signature of the Discipline Coordinator and Design Adequacy Manager, and the approval signature of the Review Team Leader.
1 TN-85-6262/2 Page 24 of 53 L
c.
.l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l
l Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES 1
.For a DIR to be classified as an unclassified deviation, or unclassified f
trend, the reviewer shall verify that a program undertaken by the C' SES P
Project does encompass' a review of all aspects of the discrepancy.
The DIR shall contain in the reference block a reference to a procedure, document, plan, etc., that contains. evidence that the discrepancy will be addressed.
After this verification and documentation on the DIR is complete, the DIR may be approved as an unclassified deviation, or unclassified trend, in an open status.
After evaluations of root cause/ generic implications (DAP-7) and any necessary corrective action plan (DAP-20) have been completed by the DAP, the unclassified deviation 1
or trend shall be closed, provided it meets other conditions for closure per this procedure.
If the DIR documents an adverse trend, the DIR shall be classified as a programmatic deficiency and shall receive the same concurrence and approval signatures as a deficiency, described in this Section 4.3.
j If the DIR documents a subject to be addressed in an Issue Resolution Report (IRR), the "D" type DIR shall be written as a primary issue similar to a primary External Source Issue discussed in Section 4.1.4.
Non-primary "D" type DIRs or non-primary External Source Issues "E" type DIRs that are related to the primary issues in an IRR shall be "trans-ferred to" the primary issues addressed in the IRR in a manner similar to that set forth in the part of Section 4..I.4 regarding combination of issues.
The primary issue DIR related to an IRR shall be written after DAP acceptance of the proposed corrective action (see DAPs 8 and 20).
If primary issues that are addressed in IRRs are deficiencies, unclassi-fled deviations, or programmatic deficiencies (adverse trends), the requirements of DAP-7 shall be met.
Regarding documentation of a trend evaluation, a DAP-7 trend evaluation or authorized substitute, such as generation of an IRR (and a trend evaluation form DAP-7-1) shall be O
1N.es.e2e2,2 peoe as er ss
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 G-ISSUES AND DISCREPANCIES U
conducted to document an identified, possibly adverse trend.
"D" type DIRs may be written or designated as primary issues irrespective of whether they are included in an IRR.
4.4 Revisions l
Changes to DIRs shall be made, verified, approved, and signed in the same manner as the original document.
Changed DIRs with necessary approvals completed shall be forwarded to the Generic Implications Coordinator for entry into the DAPTS (replacing the superseded DIR) and
. retention of the signed DIR in an auditable file.
Effective March 25, 1987, changes to DIRs may take the form of either revisions or versions.
Computer-generated DIRs shall indicate both the revision number (0, 1, 2....) and the version letter (A, B, C....).
The initial assignwnt of the revision number and version letter may be done at the time the DIR number is assigned.
Originals of new DIRs shall be defined as Revision i
O 0, vers 4en A.
The revision number sheil be changed on,y when the change to the DIR would affect the resolution of the DIR.
All other changes (e.g.
changes in classification, addition of information regarding resolution, etc) shall be indicated by a change to the version letter.
The active DAPTS will contain only the most current revision and version of DIRs.
The Generic Implications Coordinator may be delegated authority to change DIRs to incorporate new or revised information that is primarily N
used for sorting and indexing purposes (e.g., HDA numbers, review topic numbers, design activity, IRR numbers, etc.).
The Generic Implications Coordinator is authorized to add TV-supplied TDDR numbers to the DAPTs without revision of the DIR, and to revise any DIR to correct a data entry error.
Effective January 1, 1987, because of revisions to TV procedures, TODR numbers will not be required, but existing numbers may be retained.
O TN-es-ses2/2 Paae 26 or 53
i
\\
i COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PP.0CEDURE
' Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES Two hard copies of the changed DIR (with blank date blocks 'but with d
typed names of signators on the last revision / version) will be returned to the Discipline Coordinator after entry into the DAPTs.
The Disci-pline Coordinator will distribute one copy to the reviewer who is
~
assigr,ed responsibility for the DIR.
Subsequent changes will be made, Q
after review of the DIR, by mark-up and signatures on a copy of the then-current DIR.
4.5 Data Entry The Generic Implications Coordinator (or his designee) will ensure that the information from each approved Issue Record, DIR, and DIR revision is entered into the DAPTS and verified. Codes and descriptions of codes currently in the DAPTS will be distributed periodically by the Generic Implications Coordinator (or designee) to the DAP disciplines.
After verification that the information contained in the DAPTS is accurate, the signed originals w211 be filed in the controlled DAP Tracking System input files by a DAP Tracking System op'erator respons-ible to the Generic Implications Coordinator.
Externally resolved issue numbers (R-XXXX), open issue numbers (E-XXXX),
and DAP identified discrepancy numbers (D-XXXX) will be sequentially assigned by the Generic Implications Coordinator (or his designee).
These identification numbers will be noted on the Issue Records and DIRs along with the date of entry into the DAPTS.
Issue / discrepancy numbers remain unchanged throughout the conduct of the DAP except as necessary to implement changes in the DAP Tracking System structure.
O in-8s-82e m Paoe a a s3
l COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 (v7 ISSUES AND DISCREPANCIES i
4.6 Transmittal of DIRs When the revidwer has completed the preparation or revision of the DIR, the reviewer will sign the DIR and submit it to the appropriate Disci-pline Coordinator.
lk.
The Discipline Coordinator will ensure that all required signatures and approvals are obtained as delineated in Section 3.2 of this procedure and depicted in Figure 2.
When the DIR has been approved, the Discipline Coordinator will forward it to the Generic Implications Coordinator for entry into the DAPTS.
Each week the Generic Implications Coordinator (or his designee) will forward hard copies of new and revised DIRs (that meet one of the O
following conditions) received during that week to the DAP Manager for forwarding to. appropriate Project personnel.
The conditions for transmittal are:
b o
All new (Rev 0, Ver..A) DIRs All revised (i.e., new revision number) DIRs o
4.7 Comoerison of External Source Issues and DAP Discrepancies with Acorooriate CPSES Pro.iect Records of Discrepancies In order to incorporate CPSES (Project) records of discrepancies for comparison. purposes into the DAP, appropriate project records will be reviewed.
Periodic checks will be conducted to determine whether new project records warrant review, and preparation of " T" Type DIR if O
TN-8s.ezeze2 Pege 28 of s3 J
e RESPONSIBILITY FOR APPROVING CLASSIFICATION
/_}
CLASSIFICATION k
AND CLOSURE l
EXTERNAL AP RESULTS SOURCE NOT EXPLICITLY DEFINED ISSUE BY EXTERNAL SOURCE ISSUE CLOSED OPEN DISCIPLINE COORDINATOR UNSUBSTANTIATED DISCREPANCY O
OBSERVATION l
N DAP MANAGER DEVIATION REVIEW TEAM PROGRAMMATIC UNCLASSIFIED DEFICIENCY LEADER DEFICIENCY DEVIATION F!GURE 2 I
RELATIONSHIP BETWEEN CLASSIFICATION I
AND APPROVAL AUTHORITY O
TN-85-6262/2 Page 29 of 53 1
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6
]
ISSUES AND DISCREPANCIES
~
I appropriate.
These records may include documented evaluations done pursuant to 10CFR 50.55(e) and 10CFR 21 and other_ historical records of i
evaluations (such as Signific&nt Deficiency Analysis Reports [SDARs])
Q regarding design problems that are relevant to the DAP.
The purpose of these DAP reviews is to capture information regarding project-identified design problems in a format that is consistent with DAP data on External Source Issues ("E" type DIRs) and DAP identified discrepancies ("D" type DIRs).
The information taken from DAP review of project records may be used in DAP trend evaluations and Issue Resolution Reports (IRRs) even though CPSES project-identified discrepancies do not constitute.a portion of DAP-identified discrepancies.
In order to facilitate direct comparison of project records with External Source Issues and DAP-iden-tified discrepancies for trending purposes, selected project records will be documented in the format of DAP "D"
type DIRs.
The Generic Implications Coordinator shall assign a unique sequential number with a "T" prefix (T-XXXX) to each such computer record.
The identification number and date of entry into DAPTs will be noted on the DIR form.
Specific entries on "T" type DIRs are covered in Section 5.5.7.
These "T" type DIRs do not require resolution by the DAP because they represent only documentation of project findings and, through project resolution mechanisms, will be resolved.
"T" type DIRs will not become part of the DAP Tracking System as committed to in the CPRT Program Plan or other CPRT documents, and all entries required on "D" type DIRs are not required on "T" type DIRs.
As a separate data base, however, "T"
type DIRs will be available for use by the DAP in trend evaluations and IRR development.
TN-85-6262/2 Page 30 of 53 l
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 g
ISSUES AND DISCREPANCIES 4.8 Discrepancies Identified Durina Overview of Corrective Actions Discrepancies in corrective actions identified during overview activit-ies are significantly different from External Source Issues or discrep-ancies that are identified by the DAP during 'the self-initiated portions of the DSAPs.
Because these areas of design are subject to reverifica-tion or redesign, there is a need only to describe and track these l
discrepancies to closure as part of the corrective action overview described in DAP-20.
There is no need to develop or record all of the information required of discrepancies identified in the self-initiated parts of the DSAPs because trending and root cause and generic implica-tions evaluations by DAP are not applicable to corrective action activities.
The information required to be documented on the corrective action ("C" type) DIRs is contained in Section 5.5.8.
4.9 Processina of DIR Resolution Forms 4.9.1
Background
The following paragraphs provide for the processing of DIR Resolution Forms prepared by TV Electric or its contractors in accordance with TV procedure ECE 3.06-I3 (or corresponding contractor procedure) and forwarded to DAP for concurrence.
Because of the 100% design validation program to which TV has committed, the responses to DIRs are expected to include many references to new calculations or designs.
As a result, many DIRs will become " unclassified deviations."
The existing pro-visions in DAP Procedures for safety significance evaluations, root cause assessment, and generic implications evaluations are retained in the DAP program for use in the event that the DAP is called upon to provide. closure documentation.
Otherwise the provisions of this paragraph 4.9 shall apply.
TN-85-6262/2 Pace 31 of 53
l
)
4, COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 g
ISSUES AND DISCREPANCIES h
4.9.2 General Provisions The DAP Manager shall establish, maintain, and control an appropriate tracking mechanism for the receipt of DIR Resolutions from TV and its contractors, distribution to Discipline Coordinators, return to the DAP Manager, and entry into the DAPTS.
Upon receipt of DIR Resolution Forms, the DAP Manager (or his designee) shall note the receipt in the tracking ;ystem and shall distribute the forms to the appropriate Discipline Coordinator.
The Discipline Coordinators shall return a marked up computer-generated DIR form showing the classification as closed, with the version number changed to the next sequential letter, I
the classification and status revised, and the resolution and safety significance portions of the DIR completed as defined below.
If the 3
Discipline Coordinator disagrees with the resolution described on the I
Resolution Form and cannot resolve the disagreement with TV or its contractor, a new DIR shall be issued in accordance with 4.9.6.
For the purposes of paragraphs 4.9.3 through 4.9.5, " classification" shall mean the classification determined by DAP prior to receipt of the DIR Resolution Form.
4.9.3 DIRs Classified as Observations or Unsubstantiated DIRs classified by DAP as Observations or Unsubstantiated are considered closed by DAP.
The DIR Resolution Forms shall be reviewed to determine whether they contain any information that would cause the classification to change to either a deviation (including an unclassified deviation) or a deficiency.
If such information is provided, the Discipline Coordin-ator shall accept that information without further verification and revise the DIR Form accordingly.
The resolution and safety significance blocks on the DIR Form shall reference the Resolution Form and may contain any supplemental information the Discipline Coordinator deems TN-85-6262/2 Page 32 of 53
l i,
o COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE
]
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 q
ISSUES AND DISCREPANCIES V
appropriate.
If such reclassification is not necessary, the DIR classification shall remain unchanged, but the Resolution block shall be updated with a reference to the Resolution Form and whether the Resolu-tion Form indicates that TV considers the DIR to be valid.
4.9.4 DIRs Classified as Discrepancies DIRs classified as discrepancies by DAP when TV responses are received require classification change prior to closure by DAP.
The assigned
]
reviewer shall examine the Project-supplied response and determine which classifimtion is most appropriate:
unsubstantiated, observation, deviation, unclassified deviation, or deficiency.
The classification should be based on the information contained on the DIR Resolution Form supplemented as necessary with additional information obtained from TV or its contractors.
The " Description of Resolution" section on the DIR form shall be completed for, all DIRs for which responses are obtained.
O The resolution description shall reference the Resolution Form and g
supplemental information as necessary to adequately describe the bases for resolution.
For DIRs determined to be deviations, unclassified deviations, or deficiencies, the Safety Significance section shall be completed as directed in 4.9.5 below.
4.9.5 DIRs Classified as Deviations, Unclassified Deviations, or Deficiencies In general a safety significance evaluation is necessary to close a deviation.
Those deviations determined to be non-safety-significant are closed as deviations, while deviations that are safety significant are classified as deficiencies.
If such a determination cannot be made or is rendered moot by Project corrective action, the DIR is placed in the unclassified deviation category.
The assigned reviewer may use the information contained or referenced in a DIR resolution form in lieu of 7
TN-85-6262/2 Pace 33 of 53
e s
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6
/7 ISSVES AND DISCREPANCIES U
performing a safety significance evaluation.
For example, if a proposed corrective action is to revise tne FSAR to allow an alternative design, and no hardware changes are required, the DIR may be classified as a closed deviation by simply stating this rationale as the resolution basis on the DIK form.
The safety significance section of the DIR form should also state this basis.
Alternatively, when the DIR resolution form states that code requirements are not met and that hardware changes will result, the DIR should be classed as a deficiency.
The reviewer may apply his judgement to place the DIR in the unclassified deviation category if he believes either that analysis could demonstrate that the item is acceptable,or that not enough information is available to reach a firm conclusion on the safety significance of the deviation.
In any event, the safety significance section of the DIR form shall provide or reference the basis for the classification.
The " Description of Resolution" section on the DIR fore shall be completed as described in n
4.9.4 above.
d V
4.9.6 Nonconcurrence with Resolution Forms This section shall apply to those cases where either: (1) the 'DIR Resolution Form indicates that the DIR is unsubstantiated and the reviewer disagrees with the basis or (2) the corrective action is incomplete, incorrect, or otherwise less than adequate.
In such cases, the reviewer shall attempt to obtain supplemental information (written or oral) to resolve his questions.
If the question remains open, the reviewer shall prepare a new DIR in accordance with the provisions of this procedure for "C" DIRs, provided that the following conditions are met:
(1) the question remaining open shall be written to focus on the concern (i.e., if the Resolution Form resolves part of a DIR, any new DIR shall address only the unresolved part of the original DIR), (2) as a minimum, the concern meets the definition of a deviation, and (3) concurrence of the DAP Manager or the Review Team Leader is obtained TN-85-6262/2 Page 34 of 53 I
w
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 g
ISSUES AND DISCREPANCIES prior to entry into the DAPTs. The new DIR shall reference the original l
DIR.
u 5.0 DOCUMENTATION 5.1 Summary Issue Record Cover Sheets, Issue Records, QOC Issues Logs (if used) and DIRs shall be prepared using the attached forms. All pertinent informa-tion shall be documented clearly and completely as required for each different form and each type of DIR as specified in this Section 5.
A flow chart of a typical report generation process for External Source Issues and self-initiated "D" type DIRs is contained in Figure 3. This example process does not include the preparation of IRRs.
All records required by DAP General File No. 4.0 or subfiles shall be h
maintained in the TERA Bethesda Office under the control of the PGI Coordinator.
Copies may be maintained at other DAP work locations as desired.
5.2 Issue Record Cover Sheet The Source Document Title field will include the complete title of the document reviewed. For untitled documents (e.g.,
letters), the field will indicate that the document is untitled along with the subject, or contents, of the document.
The Originating / Investigating Organization field will contain the name of the organization which issued the document being reviewed.
Each External Source document reviewed will be assigned an identifica-tion number by the DAP. The Document I.D.
field will contain this CPRT h
TN-85-6262/2 Page 35 of 53
OPEN EXTERNAL ACTION PL AN SOURCE 155UES IMPLE MENT A TION 1 P OPEN ES EXTERNAL ISSUES DISCREPANCY / ISSUE RESOLUTION SUBSTANTIATE REPORT: CLASSIFY ISSUES AND
?
7 ACTION PL AN RESULTS NOT COVERED IN ISSUES AS OC DISCREPANCIES NO 1 F YES CLOSE ISSUE 1 P ON DISCREPANCY /
ISSUE RESOLUTION OTHER EVALUATE PER ACTION PLAN REPORT DISCREPANCIES REVISION OR EXPANSION P
1 P NO m
DATA ENTRY C
T pp I y NO RADE CLASSIFICATION DOCUMENT ISSUE CLOSURE IN DISC.
DISC. COORD. CONCUR D*
RESULTS REPORT COORD.
DAP MCR.. CONCUR APPROVE YES RTL. APPROVE f
SIGN F
SRT - REVIEW G
, P CLOSE DISCREPANCY REVISE DISCREP ANCY REPORT AS OBSERVATION UPCRADE TO DEVIATION ISSUE CLOSED (WITH OR wtTHOUT UNSUBSTANTIATED CORRECTIVE ACTION)
IN REVISED DISCREPANCY / ISSUE y
4 RESOLUTION REPORT v
COPY TO PROJECT DATA ENTRY W/ REQUEST FOR 1 P TDDR#
DATA ENTRY qy DATA ENTRY TDDR #
P FROM PROJECT 9 P DOCUMENT IN DISC.
RESULTS REPORT COORD.
DIRECT NO CORRECTIVE A
ACTION 1 r
?
WS ISSUE / OBSERVATION CLOSED UNCLASSIFIED DEV!ATION FIGURE 3 TN-85-6262/2 CPRT DESIGN ADEGUACY PROGRAM TRACKING SYSTEM DISCREP ANCY/ ISSUE RESOLUTION REPORT FLOW 3G of 53
CD 1 P D)
EVALUATE PER ACTION PL AN
(,
REVISION OR EXP ANSION 1 P EVALUATE SAFETY r
SIGNIFICANCE YES OTHER NO C
DISCREPANCIES p
j 1 r NO UPCRADE CLA551FICATION P
CLOSE DISCREPANCY AS DEVIATION (WITH Dl5 C.
YES CORRECTIVE ACTION COORD..
3 I EVALUATION) lN RE.
- CONCUR, OtSC.COORD.. CONCUR VISED DISCREPANCY /
REVISE DISCREPANCY REPORT DAP MGR.. CONCUR ISSUE RESOLUTION APPROVE UPCRADE TO DEFICIENCY RTL - APPROVE REPORT SRT. REVIEW 1 F h
1 P
'qO DATA ENTRY COPY TO PROJECT DATA ENTRY W/ REQUEST FOR TDDR #
1 P DOCUMENT N DISC.
RESULTS REPORT COORD.
DATA ENTRY TODR #
FROM PROJECT 1 V ISSUE / DEVIATION CLOSED ADVERSE TREND EVALUATE PER ACTION PLAN b (PROGRAMMATIC REVISION OR EXPANSION DEFICIENCY) 9 '
EVALUATE ROOT CAUSE/
CEtERIC IMPLICATION 5 l
1 P C0 FIGURE 3 (Continued)
O CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW l
TN-85-6262/2 Page 37 of 53 L
e O
IDENTIFY / EVALUATE 2
CORRECTIVE ACTION PLAN DATA ENTRY I
1 r EVALUATE CORRECTIVE ACTION IMPLEMENTATION V
ORRECTiv ACCEPT YES 1 r CLOSE DISCREPANCY AS DEFICIENCY, UNCL ASSIFIED DEVIATION OR PROCR AM.
DISC. COORD.
MATIC DEFICIENCY (WITH CORRECTIVE DAP MCR. CONCUR ACTION EVALUATION) IN REVISED RTL. APPROVE DISCREPANCY / ISSUE RESOLUTION REPORT SRT. REVIEW g
9 r DATA ENTRY 1 V DOCUMENT IN DISC.
RESULTS REPORT COORD.
1 r ISSUE / DEFICIENCY CLOSED FIGURE 3 (Continued)
O CPRT DESIGN ADEQUACY PROGRAM TRACKING SYSTEM DISCREPANCY / ISSUE RESOLUTION REPORT FLOW TN-85-6262/2 Page 38 of 53
r y
. COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l
Number:
DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6' j
ISSUES AND DISCREPANCIES identification number.
A cross-reference between Document I.D. and the title or description o~ the External Source document shall be maintain-f ed.
l' The Description field will contain any additional information needed to
. describe the document, including any document ID number assigned by the i
issuing organization.
The Addressee Organization field will contain the name of the organiza-tion to which the document is addressed (if applicable).
The Document Date field will contain either the date of issuance of the document or, if the document is a meeting transcript, the date that the meeting was held.
The number of Issue Records that are attached to the Issue Record Cover Sheet shall be recorded in the space provided.
Upon completion of the Issue Record Cover Sheet, the Reviewer and the Discipline Coordinator shall sign this cover sheet to indicate their reviews are complete.
5.3 OOC issues Loc If the Reviewer elects to use the QOC Issues Log, under the guidance of Section 4.1.2, the log can be used to either summarize the issue or refer to specific Issue Records which describe the issue in greater detail.
If the 00C Issues Log is used, it shall be signed by the Reviewer and the Discipline Coordinator.
1 O
TN-95-6262/2
. Pace 39 cf 53
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
000UMENTATON AND TRACKING OF Revision: 6 O
ISSUES AND DISCREPANCIES 5.4 Issue Record 4
Issue Records (Attachment C) are divided into 2 parts. Only Part I need be completed for open issues.
Both Parts 1 anc 2 will be completed for I
closed issues and may be used for open issues.
Since the Issue Record documents a " snapshot" of information contained in the External Source document, the Issue Record does not have a provision for revision.
It contains historical "as found" information.
l The maximum mrber of characters allowed for each field is indicated on the Issue Record.
Continuations beyond these maximum numbers of characters are acceptable.
Continuations will be made available with DIRs by placing them in a notebook at each tracking system terminal, or as an alternative in the future will be accessible within the computer-ized DAPTS. They are identified by DIR number, issue name, and revision number (if Rev. 1 or abcve).
Continuations may be entered in the DAP i
tracking system, (if they are text), or may be appended to output DIRs if they are an exhibit such as a calculation or sketch.
The Date Entered DAPTS and Issue # fields shall not be completed by the Reviewer except when an E-XXXX DlR number is received from the PGI Coordinator for a new primary issue.
Otherwise, these fields shall be completed at the time of data entry into the DAPTS.
5.4.1 Part 1 This part of the form will be completed for each issue identified during review of each source document.
l A brief title for the issue will be entered in the Issue Title field.
l The title should summarize the issue description (e.g., what is wrong and what is affected) to the extent that this information is included in l
TH-85-6262/2 Pace 40 of 53 1
1
9 9'3 3
3 4
COMANCHE PIAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2' TNie:
DOCUM'ENTA'ON AND TRACKING OF Revision: e T
E ISSUES AND DISCREPANCIES y,
.thpExternalSourcedocument,;3so that those familiar with the review may identify the issue by[its title.
Keywords may be used in the = title.
Potential cause of the issue should not be used 'as a titie.
D
'A couplete derdription of the issue, to the extent that it is documented 0-
-in the source document,.will be written in. the Issue Description field.
5 Failures to meet specific' project criteria and procedures should be
'U~
identified to the' exIent they are specified by the source document.
The source of' any information not taken directly from -the source document shall be included in: the\\de.scription.
i
'a,
Comments including resolution #statushicontainedinthesourcedocument may be added in the Description of Re,sMution/Commenis field of Part 2 whether or not the.-issue status is closed.
Thepagenumberofthesourcedo$umentonwhichtheissueisdiscussed, O
alon,withtheExternairocreeIssueidentifiernumber(inapplicable),
.will be entered in the' corresponding fields.
t 3-The structure (s), system (s), or component (s) affected wili be identified if it can be readily determined from the source document.
This identi'-
fication may include components, component types, system names, loca-tions, or structures.
The CPRT document ider,tifier number will be entered in the D0C.
10 field.
The status of the issue (as determined by the DAP) will be entered in the. status field.
Open issues must have an Action Plan number and revision entered in the corresponding fields.
If the issue has been determined to be closed, the classification of the O
TN-8s.ezer 2 Pace 41 of s3 l
l
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - ^ - ^ - - - - - ^
c I
h COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 Q
ISSUES AND DISCREPANCIES issue will be indicated in the Classification field.
If closed due to transfer to another Review Team, the issue need not be classified.
l The DAP discipline will be identified.
For disciplines - comprised of subdiscipline areas of design in DAP-7, Attachment A', the subdiscipline will also be documented if contained in the External Source document.
/dditional subdisciplines may be designated.
For open issues, and for closed issues that are not classified as unsubstantiated, it is 'noted on the Issue Record whether the source document states that the issue:
1 Is an isolated error or has potential generic implications; o
o-May have potential cumulative effects with other issues; Is considered to be a technical or programmatic concern.
o O
If this information cannot.be readily determined, the field will be left blank. Attachment E contains guidance on interpretations of these terms.
For open or closed substantiated issues, the design organization and design activity will be documented if that information can be readily determined from the source document.
The design organization is the organization originally responsible for the work affected by the issue.
The Design Activity field refers to design requirements discussed in ANSI N45.2.11-1974 and Attachment F of this procedure.
For open issues, the number of the Action Plan (including the revision I
number) under whi:h the issue will be investigated shall be written in the indicated fields.
I O
1N.ss-ezez/2 Page 42 of 53 1
a
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES If the open issue'is to be evaluated within a self-initiated part of a DSAP, the most appropriate Review Topic and Homogeneous Design Activity (HDA) numbers within that DSAP may be entered.
If the area of design associated with the issue is to be addressed in an area of the design that is subject to reverification or redesign (e.g., pit.Sg and pipe supports, cable tray supports or conduit supports) Review Tepic and HDA numbers are not required because Review Topics and HDAs do not apply to those areas of design that will undergo reverification or redesign.
If Review Topic and HDA numbers are not required, enter either "NA" in both of these fields or, at the Discipline Coordinator's option, an approp-riate Raview Topic or HDA or other corie, such as PPS for piping and pipe support issues.
5.4.2 Part 2 This part of the form will be completed (to the extent required based O
uPoa c' ssificatioa or the issue) for 11 issues determiaed to be c1osed during document review.
The basis for determining that an issue is closed will be documented in the Description of Resolution field.
This field shall also document any corrective actinn identified in the source document by the originating /
investigating organization to resolve the issue and any additional clarifying comments that the reviewer determines are necessary to document closure of the Issue Record.
The Safety Significance field documents the safety significance of the issue if the originating / investigating organization described safety significance in the External Source document.
The Root Cause field documents the root cause of the issue if determined by the. originating / investigating organization and described in the h
TN-85-6262/2 Page 43 of 53
~
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE l
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING 0F Revision: 6 (v-)
ISSUES AND DISCREPANCIES source document.
If any generic implications are discussed in the source document, they should be included in this field.
5.4.3 Sign-Off Upon completion, to the extent possible, of the Issue Record, the Reviewer shall sign at the bottom of the Issue Record.
The Discipline Coordinator shall also sign to indicate that the review is complete.
Signatures (not initials) are required on the Issue Record (and DIR) forms as of April I,1986.
Initials of the Reviewer and Discipline Coordinator are acceptable on Issue Record and DIR forms prior to April I,1986 (in lieu of signatures) based on past revisions of this procedure.
5.5 Discrepancy / Issue Resolution (DIR) ReDorts nU 5.5.I "D" Type DIRs The DIR contains information that is similar to information contained in External Source Issue Records, but the DIR information is active rather than historical.
Active DIRs are comprised of External Source Issues that were identified initially as open and all issues identified in the self-initiated parts of the DSAPs and documented in "D"
type (D-XXXX)
DIRs.
Differences between the DIR' fields and the Issue Record fields are described below.
The revision number of the DIR shall be indicated in the Revision field. The original DIR will designated as Revision 0, Version A.
l/d\\.
The "AP# From" field is used only for discrepancies that are not explicitly defined by External Source Issues.
This fiela will contain the Action Plan number (ISAP or DSAP) under which the discrepancy was
(_y
)
TN-85-6262/2 Page 44 of 53
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING 0F Revision:-6 ISSUES AND DISCREPANCIES identi fied.'
For External Source Issues, the field will contain "N/A" (not applicable).
The "AP# To" field will indicate the Action Plan-number under which the
' issue'or discrepancy is being investigated.
For example, a discrepancy identified during implementation of a TRT ISAP may be assigned to' that
-ISAP or. to a DAP DSAP if it is appropriate to evaluate the discrepancy as.part of the'DSAP.
The " Dependent On" field will contain a list of issue or discrepancy numbers which must be resolved prior to closure of the issue or discrep-ancy des'cribed on the DIR.
The Design Discipline and Subdiscipline, Type, Trend (if identified and documented in a DAP-7 trend evaluation or acceptable substitute, such as on IRR), Design Organization, and Design Activity fields shall be O
entered during the course of eva,uating or rev4s4ng DIR, r.iassified as an observations, deviations, deficiencies, programmatic deficiencies, or unclassified deviations.
Attachment E contains guidance on interpreta-tion of entries in the Type and Trend blocks.
Attachment F contains guidance on use and interpretation of the Design Activity blocks.
If the DIR resulted from implementation of a self-initiated portion (not corrective action overview) of a Discipline Specific Action Plan (DSAP),
affected Homogeneous Design Activity number (s) and the Review Topic number shall be entered.
For DIRs that describe technical issues and that originated from External Source Issues or DAP activities, other than DSAP implementation of overview of corrective actions, the HDA
]
number and Review Topic most closely related to the DIR shall be entered I
in Rev. O of "D" type DIRs or may be entered in a revision of "E" type DIRs. Documentation related to such revisions shall be filed in the DAP tracking system file or annotated on the signature copy of the revised TN-85-626?/2 Page 45 of 53 L
L
{
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE i
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES DIR.
Since HDA and Review Topic numbers do not apply to the Piping Discipline, F?S will be entered in HDA and Review Topic numbers on DIRs J
assigned to this discipline.
Review Topics and HDA numbers may not be applicable.to other areas of the DAP (e.g., areas subject to reanalysis l
or design, trends, programmatic concerns).
In such cases "NA" shall be i
entered into those locations.
The Safety Significance field will be completed only for deviations, deficiencies, and programmatic deficiencies, or primary DIRs which encompass DIRs in these former classifications.
The Safety Signifi-cance Evaluation will be conducted in accordance with DAP-22.
The Root Cause/ Generic Implications field will be completed for unclassified deviations, unclassified trends, deficiencies, and programmatic defi-f ciencies per DAP-7.
This information is not required on the DIR revision that initially classifies the discrepancy, but may be developed during evaluation of the issue and entered in a later revision to the O
ota-Prior to closure of any DIR originated from an External Source Issue or self-initiated DSAP review (other than " Transferred to:" open, closed or duplicate DIRs), all entries on the DIR that are required by this procedure for the final classification of the DIR shall be completed (e.g.,
sJaty signif.icance must be filled in for a deviation (or primary DIR covering the deviation) prior to closing the DIR).
As of April 1,1986, signatures (not initials) are required as specified in DAP-2 for the various classifications of discrepancies.
Initials on IR/DIRs prior to April 1,1986 are acceptable (in lieu of signatures) based on past revisions of this procedure, h
TN-85-626u2 Paae 46 of 53
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING 0F Revision: 6 ISSUES AND DISCREPANCIES 5.5.2 Duplicate DIRS ("D" or "E" Type)
If an identical issue or DIR is found to have been entered in the DAPTS more than once, one DIR shall be retained in the DAPTS and each other DIR that is a copy of the retained DIR shall~ be designated as "trans-ferred to" and duplicate; e.g., D-XXXX(D).
A statement that the DIR is a duplicate (copy) of another DIR shall be entered in the Description of Resolution field.
This closes the duplicate DIR and no further revis-ions or entries are required.
The "5tatus" block of each duplicate External Source "E"
type Issue or duplicate "D" type DIR shall be marked Transferred to:
"(DIR Number)"
of the primary issue.
This shall be the final revision of the duplicate issue DIR.
Duplicate "E"
type or "D" type DIRs are considered closed and will not be revised or included in trend evaluations.
O s.s.3 aeiated (Not Dupi4cate) DIRs Transferred to er4 mary Issues "E" or "D" type DIRs that are related to a technical or programmatic issue ( such as one to be covered in a primary DIR that may be the subject of an IRR), a trend, or a primary issue that is not part of an IRR or trend may be transferred to a primary issue (DIR) in either an open or closed ~ status.
The IRR number shall be entered in the IRR field on the primary DIR when the proposed corrective action is approved by DAP in accordance with DAP-20.
An "Open" transferred to DIR will contain the primary issue DIR number followed by "(0)", e.g., E-XXXX(0), or D-XXXX(0) in the status block. A
" Closed" transferred to DIR will contain the primary DIR number followed by "(C)",
e.g.,
E-XXXX(C), er D-XXXX(C) in the status block of the machine-printed DIR.
After a DIR's status is marked " transferred to (open or closed)," no further revisions are required or should be made O)
TN-85-6262/2 Paoc 47 of 53
l-i COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 i
g ISSUES AND DISCREPANCIES O
to this DIR until the primary issue (or IRR) is closed.
At closure of the primary issue, all " transferred to (open or closed-not duplicate)" issues or DIRs associated with that primary issue will be re' viewed by the discipline to ensure that each " transferred to" issue has been resolved, and then each non-primary DIR shall be designated
" Closed" in a final revision of each " transferred to" DIR.
Because the
" transferred to" cross-reference to the primary issue is the track to evaluation and resolution of the issue, only the status block shall be revised from "Open" to " Closed," that is, from E-XXXX(0) to E-XXXX(C) or D-XXXX(0) to D-XXXX(C).
The " Transferred to:" E-XXXX or D-XXXX number remains on these DIRs.
All other information that DAP-2 requires to be documented in the tracking system is entered only on the primary issue DIR.
The primary issue DIR does not list related issue "E" or "D" type DIRs that were transferred to it.
Related DIRs will be included in trend evaluations.
5.5.4 Transfer of DIRs to Other CPRT or TRT Review Teams If, during implementation of an Action Plan, it is determined that the issue / discrepancy should be reassigned to the QOC Program, or the TRT Testing or Electrical Review Teams for resolution, the issue / discrepancy will be designated as closed in the status field.
Classification, Type, Design Activity, Review Topic and HDA numbers do not need to be con-tained in those DIRs since they are not related to design. The DAPTS is used to track DIRs related to Civil / Structural, Mechanical, and Misc-ellaneous TRT issues through closure.
The Description of Resolution field will document that the issue / discrepancy was reassigned to QOC or other TRT review team, and the Reference field will reference the memo documenting that reassignment.
DIRs transferred to another CPRT review team will not be counted or considered in trend evaluations within the DAP.
The Discipline Coordinator or his designee is responsible for O
T"-8s-8282/2 eaae 48 or s3
e, COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES transmitting the DIRs to other RTLs. A receipt acknowledgement shall be requested from the Review Team Leader to whoa the O!R is transferred.
5.5.5 Unsubstantiated DIRs If an issue is determined to be unsubstantiated, the issue will be assigned a status of closed, classification will be marked unsubstan-tiated, and the basis for this determination will be documented in the Description of Resolution field.
5.5.6 Unclassified Deviations or Unclassified Trends If an issue meets the requirements of an unclassified deviation, or unclassified trend, the DIR must include a specific reference to the procedure, document, plan, etc., that encompasses the aspects of the issue that are the subject of the unclassified deviation or trend.
This O
reference must ee 14sted on the DIR form -pr4or to an approva, es an unclassified deviation or trend by the Review Team Leader.
5.5.7 DIRs Documenting CPSES Project-Identified Discrepancies Reports issued pursuant to 10CFR 50.55(e) or 10" 21 are reviewed only to document information in a form compatible to DAP DIRs.
These DIRs are identified as "T" ' type DIRs.
"T" type DIRs shall be considered complete, with no further entries needed on form DAP-2-4, when the DIR I
documents.the following information to the extent that it is contained l
in the report or supporting analysis:
o DIR No: T-XXXX o
Rev No:/Ver No:
o Entry Date O
TN-85-6262/2 Page 49 of 53 l
COMANCHE PEAK RESPONSE TEAN - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES o
Issue / Discrepancy Title o
Description of Issue / Discrepancy o
Structure (s), System (s) or Component (s) Affected o
Discipline o
Design Organization o
Design Activity o
Description of Resolution o
References Review Topic and HDA (when applicable) o o
Safety Significance o
Root Cause/ Generic Implications Review and approval signatures of Reviewer and a Discipline o
Coordinator.
These DIRs are to be used as supplemental information durine trend analyses or root cause/ generic implications evaluations of DAP-identi-fied discrepancies or External Source Issues.
No entries for status, classification, t3pe, trend, or subdiscipline are required on the "T"
type DIR.
5.5.8 DIRS Documenting Discrepancies Noted in Overview Corrective Action DAP-20 requires that DIRs be written to document discrepancies identi-fied by DAP in the overview of corrective actions except in cases where such d;screpancies are transmitted to TU Quality Assurance for incorp-oration into appropriate TV audit documentation.
Any DIRs issued to g,
meet this requirement are issued only to track these discrepancies until resolution.
These DIRs are written on form DAP-2-4, and are assigned O
Tu-8s-8282/2 Pece s0 or s3
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 ISSUES AND DISCREPANCIES "C" type DIR numbers.
They are subject only to the following documen-tation requirements:
I o
DIR No: C-XXXX o
Rev No:/Ver No:
d o
Entry Date o
Issue / Discrepancy Title o
Description of Issue / Discrepancy o
AP# From o
AP# To o
Structure (s), System (s) or Component (s) Affected o
Status o
Dis;ipline Design Organization (doing reverification or redesign) o o
Description of Resolution o
References o
Signatures (of Reviewer and approval of Discipline Coordina-tor).
Because these corrective action
("C" type) DIRs are only to track l
corrective actions, classification, type, trend, design activity, Review Topic, HDA, TDDR#, safety significance and root cause/ generic implica-tions entries are irrelevant. These DIRs will not be included in trend l
evaluations as they are not relevant to DAP reviews of original designs within the self-initiated parts of DSAPs Revisions to "C"
type DIRs shall be used as appropriate to update the DIR information.
"C" type DIRs shall be closed when corrective action overview per DAP-20 has been accomplished.
O
_ TN-8s-s2e2/2 ease si of s3 1
[
COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE 1
Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: e ISSUES AND DISCREPANCIES 5.5.9 Backfit of "C" Type DIRs Discipline Coordinators are responsible for identifying DIRs prepared prior to the approval of Rev. 4 of DAP-2 that address DAP overviews of corrective action, and shall ensure that these DIRs are transferred to "C" type DIRs as follows:
Change the Status to Transferred to C-XXXX(D);
o State whether the overview discrepancy is open or closed; o
In the Description of Resolution block, write:
"This DIR D-o XXXX resulted from an overview of corrective action and has been renumbered as a "C" type DIR."
I Sign the DIR form (only the Discipline Coordinator's signature o
is required);
Send the DIR to the Generic Implications Coordinator for data o
entry.
Upon receipt of the DIR, the Generic Implications Coordinator shall ensure that the existing "D" type DIR is. transferred to a "C" type DIR as follows:
Revise the "D" tyoe DIR to reflect any changes in the incoming o
revision, including status and the next revision number, Assign a C-XXXX DIR number in the status block of the "D" type o-DIR.
o copy the revised DIR, assign the same C-XXXX DIR number (Rev. 0), change the status field to open or closed as indicated on the incoming revision, and ensure that a refer-ence to the duplicate "D" DIR number in the incoming revision is included in the record.
Delete information from the incoming DIR from fields that are o
not required to be included in the "C" type DIR.
O 1N-8s-82e2 2 eeoe s2 or s3
r COMANCHE PEAK RESPONSE TEAM - DESIGN ADEQUACY PROCEDURE Number: DAP-2
Title:
DOCUMENTATION AND TRACKING OF Revision: 6 I Q ISSUES AND DISCREPANCIES Unless otherwise approved by the DAP Manager or the RTL, Discipline Coordinators shall complete the backfit of "C" type DIRs by October 31, l
1986 or four weeks from the approved date of Rev. 5 of DAP-2 (whichever islater).
5.6 SRT Review of DIRs The Senior Review Team may review any DIR and identify the need for clarification, expansion of review or reassessment by DAP personnel.
O TN-85-6262/2 Page 53 of 53 I
ATTACHMENT A s
COMANCHE PEAK DESIGN ADEOUACY PROGRAM ISSUE RECORD COVER SHEET Q
Source Document
Title:
Originating /! investigating Organization:
Document ID:
==
Description:==
Addressee Organization:
Document Date:
No. of Issue Records Attached:
Signatures:
O-sevie-er oote oisciaitee cooraimotor oote FORM DAP.2 1 REV.0 0
TN-85-6262/2 A-l
s ATTACHMENT B
/^
COMANCE PEAK DESIGN ADEQUACY PROGRAM CONSTRUCTION /GA/QC ISSUES LOG Brief issue Description Identifier #
Page#
i 1
i O'
I I
Signatures i
~
Reviewer Date Discipline Coordinator Date Form DAP-2-2
' (TN-85-6262/2)
B-l Rev.0'
x ATTACHMENT C
.w COMANCHE PEAK DESIGN ADEGUACY PROGRAM Date Entered DAPTS:
ISSUE RECORD issue #:
PARTl
'ssue
Title:
4 no)
{
Description of Issue:
(no identifier #:
um Page #:
(s)
Doc. ID nm Structure (s), System (s) or Component (s) Affected:
Um Sfotus:
Class (Closed iswes Only):
a open a Closed g g,,,rv,,,,n g g,,,,;,,ey i
Programmatic Deficiency D Deviction O Unsubstantiated Discip!!ne gE
/l&C D her:
- 1. O hrl:
O Isolated D Piping
- 2. O Cumulative O Not Cumulative Subdiscipline:
3' U U "'* ** 'i' w
4
. Design Organization:
(m Review Topic #:
HDA #s:
Design Activity:
O Program Req.
O Interface Control O Change Control O Input O Verification Q Corr. Action O Process O Document Control O Audits O Investigate Further Through Action Plan #:
Um Rev.
PART2 Description of Resolution / Comments:
(62M Sofety Significance Documented:
0 781 Root Cause/ Generic Implications Documented:
0 07)
\\
Signatures:
Reviewer Date Discipline Coordinator.
Date FORM DAP.2 3 TN-85-6262/2 C-l Rev. 4
. ATTACHMENT D
.s COMANCE PEAK DESIGN ADEQUACY PROGRAM Date Entered DAPTS:
DISCREPANCY / ISSUE RESOLUTION REPORT issue / Discrepancy #:
Rev. #:
-q lssue/Discreponey
Title:
,,o3 bescription of Is::ve/Discreponey:
(62 0 AP #: From:
To:
Dependent On:
go, Structure (s), System (s) or Component (s) Affected:
(131)
Status:
Class:
D Discreponey D Unclass Deviation D Open D Closed D Unclassified Trends D Observation D Deficiency D Transferred to:
O Programmatic Deficiency D Deviation D Unsubstantiated Discipline:
O Mech'.
O C/S Type:
- 1. O cenerre D isolated D Elec.Il&C D Cen. Impt.
- 2. O Cumulative O Not Cumulative O Piping D Others
- 3. O Technical D Programmatic Subdiscipline:
au Trend:
- 1. O Adverse O Nonodverse Design Organization:
g73 HDA #'s:
gog Design Activity:
O Program Req.
O Interface Control O Change Control (one or more)
D input O Verification D Corr. Action Review Topic #:
(o O Process D Document Control D Audits IRR #:
Description of Resolution (incl. Corrective Action) urn d
TDDR #
G/
1
- gio,
References:
I l
non Safety Significance:
{
0 78)
Root Cause/ Generic Implications:
l l
0 70)
Signotures Reviewer Discipline Coordinator TRT/DAP Monoger
. Review Team Leader Date Date Date Date SRT Comments (As Required):
1 ars)
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ATTACHMENT E 1
INTERPRETATION 0F DAP TRACKING SYSTEM
" TYPE" BLOCKS L Type ~: -
Generic or Isolated Cumulative or Not Cumulative Technical or Programmatic Trend - Adverse or Nonadverse L
~All four of these choices should be-interpreted within the confines of the
. discipline; Clarification of terms. follows:
Generic means.that the discrepancy applies or potential-o ly applies to other aspects of design within the-discipline related to the DIR.
For example,.use of SRSS in combining dead weight and seismic loads is generic to the piping / pipe support discipline since this error appears to have occurred extensively (if not throughout) that discipline. Marking " Generic" in this example does not imply that the same error occurred outside the discipline indicated in the DIR.
If the same error is found in other disciplines, whether it is generic to
't these other disciplines is determined on a discipline-by-discipline basis.
Isolated should be checked if the discrepancy described o
in the DIR appears to be an error whose characteristics make it_ unlikely to have spread to other aspects of design within - the discipline.
For example, technical aspects of an error in a calculation of-post-LOCA hydrogen generation _would be isolated by the narrow scope of this aspect of design.
If. a programmatic aspect of this error could apply to other activities (such as control of _ design inputs) in the discipline, this programmatic aspect would be described in another
- DIR, and programmatic and generic blocks would be checked.
Cumulative should be checked if the discrepancy describ-o ed in the DIR is believed to impact the design in combination with other identified discrepancies.
For example, small unconservatisms may usually be neglected I
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If it were confirmed that mostaof the conduit supports are designed to maximum capacity, the cumulative effect of many unconservatisms may be significant.
All DIRs considered to have a cumulative effect on the design should be checked cumulative.
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Not Cumulative should be checked if the discrepancy V
described in the DIR is by its nature not likely to impact the design if considered in combination with other discrepancies.
For example, if an error in a calculation has no significant impact on a design output, then this error cannot have a cumulative effect with any other discrepancy, and it should be marked not cumulative, Technical should be checked if the discrepancy described o
in the DIR relates to a technical concern.
For example, DIR D-0019 states that "TUGC0 Calc. SRB-109C, SFT 3, Rev. 6 contains a modeling error and two unjustified assumptions that are important to the results."
This DIR is correctly described as technical.
o Programmatic. should be checked if the discrepancy described in the DIR relates to a design pr design control process (e.g., program, process,ocess or proced-ure, work activity, methodology, or similar. programmatic aspect of design).
For example, if during review of a technical discrepancy, it becomes apparent that a procedure for controlling the design work associated with the technical discrepancy was inadequate, in-complete, not implemented, or nonexistent (if a pro-cedure was required or committed to), then this new
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discrepancy should be documented in a new D-XXXX DIR and i
marked programmatic.
Similar to the above inter-pretation of the term " generic," a programmatic discrep-ancy should be interpreted within the confines of the discipline in which it was found.
This does not mean that the discrepancy is programmatic to other disci-plines although it may be.
If a discipline coordinator believes that the discrepancy could likely affect other disciplines,. then DAP-7 requires that the discipline coordinator identify the discrepancy to the Programmatic / Generic. Implications Coordinator and other potentially affected discipline coordinators.
Checking the programmatic block alerts the PGI coordinator to the possibility of effects on other disciplines.
Similar or related programmatic discrepancies will be identified or confirmeo through trend evaluations of discrepancies across disciplines.
1 Trend - Adverse should be checked if the DIR is the o
result of a trend evaluation of design discrepancies and has been determined to constitute an adverse trend.
A trend is con-sidered to be adverse if it is determined that the identified pattern or commonality is likely to have resulted in the occurrence of an undetected safety-significant deficiency in the affected design area.
To mark the Trend block, a trend evaluation, documented per V
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u DAP-7 on form DAP-7-1,- must have been completed.
o Trend - Nonadverse should be checked if the DIR is the.
result of a trend evaluation of design discrepancies and has been determined to constitute a trend, but the trend is not adverse (not likely to have resulted-in the occurrence of an undetected safety-significant deficiency in the area affected).
To mark the Trend block, a trend evaluation, documented per DAP-7 on form DAP-7-1, must have been completed.
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ATTACHMENT F J
USE AND INTERPRETATION 0F DESIGN ACTIVITY k
The DIR form contains nine design activities (DESACT) that are broad
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categories of' various aspects.of design.
These design activities are based on ANSI N.45.2.11-1974. They are used in initial trending of. discrepancies, 1
and they are contained in Attachment A, Example Attributes Matrix, of DAP as Level II attributes.
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.The' design activities that are associated. with the discrepancy should be checked when the DIR is written, or when the DESACT is. identified and the DIR-is. revised in the course of evaluating. the. discrepancy.
If the discrepancy. relates to more than one DESACT, multiple DESACTs may be checked. The DAPTS tracking system is configured to capture combinations of i
DESACTs if more than one applies.
. DESACT is a key. attribute used in trending and generic implica-tions evaluations.
In trending, for example, counts of the DIRs that show each DESACT and combinations of DESACTs are used to determine the distribution of
.DIRs among DESACTs.
When DESACTs are combined with other attributes, such as cuts 'oy discipline, subdiscipline, design organization, type,. and classification, the resulting distributions of numbers of DIRs in these combinations (subsets) can be identified, displayed, and analyzed.
If these-
~ distributions are skewed so that some combinations have large numbers of discrepancies, then this pattern is indicative of a trend.
Level III information in DAP-7, Attachment A, is intended to assist in ensuring proper Level II DESACTs are marked in the DIR.
Interpretations of design activity attributes follow. These interpretations supplement descriptions found in ANSI N45.2.11-1974:
o Program Requirements Specifies that there be program procedures addressing organizational structure, authority, responsibility, interfaces, management, and requirements related to the other design activities listed below.
For example, discrepancies that resulted because procedures were found not to exist to control a particular design activity should be categorized as Program Requirements.
o Input Requirements - Specifies requirements to ensure that design inputs or changes in these inputs (those criteria, parameters, bases, or other design requirements, including fregulatory requirements, codes and standards, upon which detailed final. design is based) are identified, documented, reviewed, approved, and controlled.
Level III of Attachment A to DAP-7 contains a listing of kinds of design inputs that may apply. This list is not all inclusive.
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Design Process - Specifies the use of procedures sufficient
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to ensure that applicable design inputs are correctly translated into specifications, drawings, procedures, or instructions, and to ensure that appropriate quality standards and changes thereto are identified, documented, reviewed, approved, and controlled.
In a broad sense, cl1 design activities may be considered part of the design process.
For the purpose of marking design process as an affected DESACT on a DIR, however, a narrower interpretation should be used.
That is, design process relates to controls (job specifications, work instructions, planning sheets, procedure manuals, test procedures, or any other type of written form) and the implementation of these controls applied to analyses, calcula-tions, and other direct work activities used to produce design output
- drawings, specifications, or other documents.
Interface Control - Specifies requirements for external and o
internal interfaces.
These interfaces are relationships between companies (external) and design groups or organizations within a company (internal).
Requirements related to identifying interfaces in writing, defining, and documenting responsibilities, establishing lines of communication, controlling the flow of design information, and documenting design information (including changes) transmitted in drawings, specifications, or other controlled n
documents.
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Verification - The process of reviewing, con-firming, or o
substantiating the design by one or more methods to provide i
assurance that the design meets the specified design inputs.
Verification methods include. design
- review, alternate calcula-tions, and qualification testing.
Attachment A to DAP-7 includes 15 aspects of design reviews that are based on ANSI N45.2.11-1974.
The extent of design verification required is a function of importance to safety, complexity, degree of standardization, state-of-the-art, and similarity to previously proven designs.
Where changes to previously verified designs have been made, design verification is required for the changes, including evaluation of the effects of those changes on the overall design.
Document Control - Specifies requirements for procedures to o
control issuance of ' design documents and changes thereto.
Document control requirements relate to preparation,
- approval, issuance, and revisions of design documents.
Procedures cover responsibilities for preparing, reviewing, approving,
- issuing, and revising documents, identifying documents, coordinating, and controlling interface documents,
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ascertaining that proper documents are used, and establishing distribution lists that are updated and current.
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Il-Document control should be checked if DIRs are written for V
discrepancies in licensing documents, such as the FSAR or I
revisions or updates to the FSAR, that are noted during a review.
In such cases, the DIR description should identify the licensing document and the discrepancy in it that was found.
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Change Control Specifies requirements for controlling
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changes to approved design documents to assure that impacts of changes are carefully considered, required actions are 3
documented, and change information is transmitted to all affected persons and organizations.
changes shall be justified and subjected to design control measures commensurate with those applied to the original design.
Reasons for changes listed in Attachment A of DAP-7 are valuable as attributes in determining whether change control is involved because they may indicate a pattern of why changes occurred (e.g.,
unsatisfactory test
- results, interference, disposition of nonconformances, failure to meet functional requirements, etc.).
Documents which reflect design changes are reviewed and approved by the same groups or organizations which reviewed and approved the original design documents.
o Corrective Action - Specifies requirements for procedures for reporting deficiencies and determining corrective action of
/7 specific errors.
In addition, for significant or recurring V
deficiencies, determining the cause and instituting changes in the design process or quality assurance program to prevent recurrence of similar types of deficiencies is also required.
Attachment A of DAP-7 lists examples of objects of corrective action (e.g.,
design activities, procedures, personnel, training, and management).
For exam-ple, if an error had been detected in the past and corrective action was taken, but the same type of error continued to recur, then corrective action would be checked as an attribute on the DIR because corrective action was apparently ineffective.
o Audits Specifies requirements to plan,
- conduct, and document audits to verify compliance with all aspects of the QA program for design.
If a discrepancy relates to failure to conduct audits, inadequacy of audits, or failure to follow up on correcting findings resulting from audits, then this DESACT should be checked on the DIR.
The next step in trending is to determine, based on engineering judgement, whether the problem documented in tbse DIRs (with-final classifications) in the subsets that exhibit trends is likely to constitute an adverse trend.
If an adverse trend is likely to exist, a DIR classified as a programmatic deficiency is written, without first performing a safety significance evaluation.
The formal safety significance evaluation, root cause and generic implications evaluations are done in the process of evaluating the i
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(Q programmatic deficiency.
This information, as to where the trend applies, V
(how widespread is the problem), what organization and discipline were involved, and what is the cause of the trend will be developed as part of evaluations of the trend regarding safety significance (not required for unclassified trends), root cause and generic implications.
If a trend is identified based on DIRs that have not received final classifications, the trend shall be considered potentially adverse and preliminary until all DIRs in the trend receive final classifications.
The end result of identification of an adverse trend is a conc se description of a problem. This description could have been originated based on judgement of DAP personnel and confirmed by analyzing the DIR data.
Alternatively, the description may ha','e been originated as a result of analyzing the DIR data and confirmation by one or more DAP disciplines.
Problem description also precedes determining why the trend occurred (root cause or causal factors), and whether it affects other areas of design not yet identified (generic implications).
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